Crosswalk pair
GDPR and NIST SP 800-171, control by control
9 canonical controls in Keel’s library satisfy clauses of both GDPR and NIST SP 800-171. Implement each once, attach the evidence once, and it counts toward each standard. The overlap is the work you don’t repeat.
The overlap
What the two libraries have in common
Every figure here counts canonical controls in Keel’s library, not clauses of either standard. Each standard’s own authored count is on its framework page.
9
Controls that satisfy both
Canonical controls that crosswalk to at least one clause of each.
22
In Keel’s library for GDPR
41% of them also map to NIST SP 800-171.
12
In Keel’s library for NIST SP 800-171
75% of them also map to GDPR.
41
Evidence artifacts expected
Across the shared controls, from Keel’s evidence guidance. Gathered once.
-
GDPR 41%
9 controls of 22 in Keel’s library for GDPR also map to NIST SP 800-171.
-
NIST SP 800-171 75%
9 controls of 12 in Keel’s library for NIST SP 800-171 also map to GDPR.
The mapping
Controls that satisfy both
Each row is one control in Keel’s library and the clauses it answers on each side. Do the work once; both columns are then evidenced by the same artifacts.
| Canonical control | GDPR clauses | NIST SP 800-171 clauses |
|---|---|---|
| Access control policy Rules for granting, reviewing, and revoking access to systems and data based on business need and least privilege; anyone who works with sensitive data, or in a place from which it can be reached, is individually authorized for that work or supervised while doing it; and a documented emergency route exists to obtain the data when the normal access path is unavailable, with every use of that route recorded and reviewed afterwards. | Art.32(1) | 3.1.1, 3.1.5 |
| Multi-factor authentication Documented procedures verify that a person or system seeking access to sensitive data is the one it claims to be, on every path by which that data can be reached - and multi-factor authentication is the enforced mechanism for remote access, administrative access, and access to sensitive systems and data. The multi-factor mechanism itself is configured so it cannot be bypassed, so the factors it uses are genuinely independent of one another - one factor’s success granting no knowledge of and no route around another - and so access is refused unless every factor required has succeeded. | Art.32(1) | 3.5.3 |
| User provisioning & deprovisioning Joiner/mover/leaver process to grant, change, and promptly remove access across systems, in which every person is issued an account of their own carrying a unique name or number, so an action in a log traces back to one named individual rather than to a shared or generic login. Each person’s right of access is recorded when it is established and reviewed on a schedule thereafter, as well as granted and changed - so what someone holds is a documented position that has been looked at again, not the accumulated residue of past requests - and what may be granted follows the organization’s access authorization rules rather than the judgement of whoever processes the request. | Art.32(1) | 3.1.1 |
| Data classification & handling Information is classified and handled per its sensitivity, with rules for labeling and protection - including the everyday handling rules that stop it being seen, overheard or picked up by people with no business reading it, so exposure that happens incidentally alongside legitimate work is limited rather than accepted. The handling rules are written to cover disclosure that nobody intended as much as disclosure that somebody chose, they say what an unauthorized disclosure is against the organization’s own privacy and confidentiality rules rather than leaving that to judgement in the moment, and they reach every medium the information travels in - spoken, on paper, on a screen and in a system - because the incidental exposure they exist to limit does not respect the boundary between an administrative, a physical and a technical safeguard. | Art.5(1) | 3.8.4 |
| Encryption in transit & at rest Strong cryptography protects sensitive data in transit over public networks and at rest in storage. | Art.32(1) | 3.13.8 |
| Logging & monitoring Security-relevant events - including successful and failed log-in attempts - are logged, protected, retained, and reviewed for anomalies, and the discrepancies that review finds are reported to the people who act on them. The review runs on a defined cadence and covers the records of system activity as a set - the audit logs, the reports of who accessed what, and the record of security incidents - rather than the log stream alone. | Art.32(1) | 3.3.1, 3.3.5, 3.3.8 |
| Vulnerability management Regular scanning, prioritization, and remediation of vulnerabilities across systems and applications, fed by current information about threats and weaknesses collected from outside the organization as well as from its own scans - vendor and industry security advisories for the software actually in use, and the threat feeds, bulletins and sector reporting that describe how systems like these are being attacked now - which is gathered continuously rather than at the next scan, evaluated for whether it applies here, and used to decide what is looked for and what is fixed first. | Art.32(1) | 3.11.2, 3.11.3 |
| Incident response A documented, tested plan to detect, triage, contain, remediate, and communicate security incidents, and to mitigate - so far as is practicable - the harmful effect of a use or disclosure of personal data the organization knows breached its own policies or the law. Each incident is recorded together with its outcome - what happened, what was done about it and how it ended - as a record of that incident, which is a different artifact from the plan being documented. The mitigation duty runs to violations by the organization itself AND to violations by the processors, vendors and other parties handling that data on its behalf: the plan reaches an incident somebody else caused with the organization’s data, so learning of one triggers the same containment and remediation as an incident inside its own walls rather than a request that the other party deal with it. Where an incident carries a duty to tell someone outside the organization, the plan discharges it on the clock the applicable law sets rather than whenever the investigation happens to conclude: whether an incident is notifiable is decided against written criteria rather than argued after the fact, the regulator or supervisory authority is notified inside the deadline that regime states, the people whose data is affected are told where the risk to them warrants it, and where a deadline is missed the notification itself explains the delay instead of passing over it. | Art.33(1), Art.34(1) | 3.6.1, 3.6.2, 3.6.3 |
| Security awareness training Ongoing security and data-handling awareness training for all personnel, with completion tracking, and periodic security updates - reminders, bulletins and alerts - issued to the workforce between training cycles. New joiners are trained within a defined period of starting, anyone whose work is affected is retrained within a defined period after a material change to the policies or procedures, and every completion is recorded. | Art.32(4) | 3.2.1 |
Beyond the pair
Where else this work counts
A framework is lit when a shared control above also maps to it. Unlit means none of them do — an absence, not a judgment about that standard.
Also reached by these 9 controls
- AI Governance Essentials
- Amazon Appstore Child-Directed Apps
- Apple App Store Kids Category
- CIS Critical Security Controls
- COPPA
- ESG Essentials
- EU AI Act
- Google Play Families
- HIPAA
- ISO 9001
- ISO/IEC 27001
- ISO/IEC 42001
- NIST AI Risk Management Framework
- NIST Cybersecurity Framework
- NIST SP 800-53
- PCI DSS
- SOC 2
- SOX (Sarbanes-Oxley) Section 404
- US Employment Law - Federal Baseline
The thesis
Why this is one project, not two
On a crosswalk-native model, NIST SP 800-171 mostly lights up controls you already built for GDPR. You’re not re-uploading the same screenshot for a second audit. You apply the framework and see the genuine delta worth working. That’s the whole idea behind collect once, comply everywhere.
Next step
Add NIST SP 800-171 to the work you already did
Apply both frameworks in one workspace and see the overlap measured against the controls you already hold.